Opinion
19076-19L
08-18-2021
Catherine S. Toulouse Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Joseph Robert Goeke Judge
Pursuant to the determination of this Court as set forth in its Opinion (157 T.C. No 4), filed August 16, 2021, it is
ORDERED that petitioner's Motion for Summary Judgment, filed December 30, 2019, is denied. It is further
ORDERED that respondent's Motion for Partial Summary Judgment, filed March 6, 2020, is granted. It is further
ORDERED that the parties are directed on or before October 15, 2021, to file with the Court joint or separate written reports as to whether they believe trial is necessary with respect to petitioner's liability for the I.R.C. sec. 6651(a)(2) addition to tax.